Sources#

Source ids, titles, publishers, URLs, access dates and fetched/not-fetched markers are carried over verbatim from _research/variable-annuity.md, the citation ground truth for the [S#]/[R#] tags used in product-spec.md and technical-notes.md. Ids are never renumbered. Sources present in the research file but not cited in either document are dropped; none were dropped here — all of S1–S8 and R1–R13 are cited. No new sources were fetched at drafting, so nothing below is marked “added at drafting”.

Access date for all citations: 2026-08-04, except the four AP&P Manual appendix entries R151, R153, R156 and R157, accessed 2026-08-06 and added to this directory afterwards.

Retrieval note carried over from the research file: sec.gov and efts.sec.gov return HTTP 403 to a plain fetch. All SEC documents below were retrieved with an explicit declared User-Agent (SEC’s stated requirement for programmatic access) and read in full as text. Every document marked “Retrieved: YES” was actually downloaded and read.

Primary product sources [S#]#

S1. Jackson National Life Insurance Company — Perspective II® Flexible Premium Variable and Fixed Deferred Annuity — statutory prospectus dated April 28, 2025#

  • Publisher: Jackson National Life Insurance Company, through Jackson National Separate Account – I (CIK 0000927730)

  • Doc type: SEC Form N-4 statutory prospectus, filed as Form 485BPOS (accession 0000927730-25-000086), ~4.9 MB HTML

  • URL fetched: https://www.sec.gov/Archives/edgar/data/927730/000092773025000086/ck0000927730-20250422.htm

  • Retrieved: YES (converted to ~1.28 MB plain text and read in relevant part)

  • Role in this library: implementation anchor. Full GLWB/GMDB algebra (GWB, GAWA, Bonus Base, step-up, GWB adjustment, excess-withdrawal proportional reduction), the charge-increase/opt-out mechanic, the contract-value-zero regime, and Appendices F–J of historical rate tables.

S2. Jackson National Life Insurance Company — Perspective II® Initial Summary Prospectus (Summary Prospectus for New Investors), April 28, 2025#

  • Publisher: same as S1; filed as exhibit EX-99.(o)(1) to the S1 registration statement

  • Doc type: Rule 498A Initial Summary Prospectus (~16 pages)

  • URL fetched: https://www.sec.gov/Archives/edgar/data/927730/000092773025000086/jnlpiiafter6-24x19initials.htm

  • Retrieved: YES (full text read)

  • Role in this library: the base contract charge stack, withdrawal charge schedule, contract maintenance charge, fund expense range and premium limits.

S3. Jackson National Life Insurance Company — Rate Sheet Prospectus Supplement dated April 27, 2026 (Perspective II)#

  • Publisher: same as S1; SEC Form 497 (accession 0000927730-26-000157)

  • Doc type: rate sheet prospectus supplement (6 pages) — the document that carries the currently offered rider charges, GAWA percentages, bonus percentages, GWB adjustment percentages and GMDB roll-up percentages

  • URL fetched: https://www.sec.gov/Archives/edgar/data/927730/000092773026000157/jnlpiiafter6-24x19rateshee.htm

  • Retrieved: YES (full text read)

  • Role in this library: the dated current parameter set (rate-sheet date 2026-04-27) for the representative GLWB and GMDB elections.

S4. American General Life Insurance Company (Corebridge Financial) — Polaris Advisory Variable Annuity — prospectus dated May 1, 2026#

  • Publisher: American General Life Insurance Company, Variable Separate Account (CIK 0000729522); SEC Form 485BPOS, accession 0001193125-26-186414

  • URL fetched: https://www.sec.gov/Archives/edgar/data/729522/000119312526186414/d79162d485bpos.htm

  • Retrieved: YES (~732 KB plain text; fee table, living-benefit and death-benefit sections, Appendix C fee formula and Appendix H examples read)

  • Role in this library: the VIX-linked non-discretionary rider fee formula variant, the Secure Value Account investment requirement, the daily-step-up design, and the cited fact that the rider fee stops when contract value falls to zero.

S5. American General Life Insurance Company (Corebridge) — Rate Sheet Prospectus Supplement dated May 1, 2026 (Polaris Advisory)#

  • Doc type: SEC Form 497, accession 0001193125-26-164551 (3 pages)

  • URL fetched: https://www.sec.gov/Archives/edgar/data/729522/000119312526164551/d113668d497.htm

  • Retrieved: YES (full text read)

  • Role in this library: cited for the rate-sheet mechanism (current withdrawal and income percentages reset by Form 497 filing with a 10-day advance-filing commitment).

S6. American General Life Insurance Company (Corebridge) — Polaris Choice IV — prospectus dated May 1, 2026#

  • Doc type: SEC Form 485BPOS, accession 0001193125-26-173379

  • URL fetched: https://www.sec.gov/Archives/edgar/data/729522/000119312526173379/d97533d485bpos.htm

  • Retrieved: YES (~503 KB plain text; fee table, penalty-free withdrawal, nursing home waiver, purchase-payment and issue-age rules read)

  • Carried-over note: “This contract is no longer available for purchase by new contract Owners.” S6 — it is a recently-sold, currently-in-force design.

  • Role in this library: the commission-share charge/withdrawal-charge trade-off, the ±0.25%-per-quarter VIX fee band for the commission class, and the GLWB RMD relief rule.

S7. Equitable Financial Life Insurance Company / Equitable Financial Life Insurance Company of America — Retirement Cornerstone® Series — prospectus dated May 1, 2026#

  • Publisher: Separate Account No. 70 (CIK 0001537470) and Equitable America Variable Account No. 70A; SEC Form 485BPOS, accession 0001193125-26-169230

  • URL fetched: https://www.sec.gov/Archives/edgar/data/1537470/000119312526169230/d120089d485bpos.htm

  • Retrieved: YES (~1.45 MB plain text; definitions, benefits, GIB mechanics, charges and expenses sections read)

  • Role in this library: the unbundled daily charge components (the source of the 0.30% administrative component in the representative charge decomposition), the Treasury-formula roll-up rate variant (10-year CMT + 1.00%, floored 4%, capped 8%), the bifurcated account architecture, and the annual (not quarterly) rider charge frequency exception.

S8. The Lincoln National Life Insurance Company — Lincoln ChoicePlus℠ product suite / Lincoln ChoicePlus Assurance℠ — Form N-4 post-effective amendment filed April 23, 2026 (prospectuses and rate sheets dated May 1, 2026)#

  • Publisher: Lincoln Life Variable Annuity Account N (CIK 0001048606); SEC Form 485BPOS, accession 0001104659-26-047599 (~20 MB HTML bundling several rate-sheet supplements and prospectuses)

  • URL fetched: https://www.sec.gov/Archives/edgar/data/1048606/000110465926047599/tm265235d1_485bpos.htm

  • Retrieved: YES (~2.68 MB plain text; the three Lincoln ProtectedPay®/4LATER®/ i4LIFE® rate sheets, the Key Information and Fee Tables, the ProtectedPay Enhancement/Account Value Step-up mechanics, and Appendix C discontinued-rider charges were read)

  • Role in this library: the step-up-triggered fee reset variant with its reversing opt-out and the no-opt-out $100,000-premium trigger; the two-table post-depletion payout variant; the explicit enhancement-vs-step-up mutual-exclusivity rule that settles the std bonus/step-up ordering; and the GMDB-priced-into-M&E design.

  • Carried-over caveat: Lincoln share-class attribution is ambiguous — the accession bundles several rate sheets and prospectuses, and the fee table read cannot be attributed with certainty to a single named product among the ChoicePlus Assurance share classes.

Regulatory and actuarial references [R#] (product research file numbering)#

R1. NAIC — Valuation Manual, Jan. 1, 2026 Edition — VM-21: Requirements for Principle-Based Reserves for Variable Annuities#

  • Publisher: National Association of Insurance Commissioners

  • URL fetched: https://content.naic.org/sites/default/files/pbr_data_valuation_manual_current_edition.pdf

  • Retrieved: YES (457-page PDF downloaded; VM-21 occupies PDF pages 142–226, manual pages 21-1 through 21-76; Sections 1, 2, 3, 4, 6, 7, 10 read)

R2. NAIC / Oliver Wyman — “Variable Annuity Statutory Reserve and Capital Reform — QIS II Executive Summary”, February 12, 2018#

  • Publisher: NAIC Variable Annuities Issues (E) Working Group (report by Oliver Wyman)

  • URL fetched: https://content.naic.org/sites/default/files/committee_related_documents/cmte_e_va_issues_wg_related_qis_ii_executive_summary.pdf

  • Retrieved: YES (13-page PDF; background and QIS I/QIS II overview read)

R3. NAIC — Life Risk-Based Capital instructions, LR027 Interest Rate Risk and Market Risk (C-3 Phase II for VAs)#

  • Publisher: NAIC Capital Adequacy (E) Task Force

  • URL fetched: https://content.naic.org/sites/default/files/inline-files/LR027%20mod%20for%20vol%20res%202020.pdf

  • Retrieved: YES (5-page PDF; full 7-step process, CTE(98) definition, RBC formula, phase-in and smoothing read)

R4. American Academy of Actuaries — “Implementation of Requirements for Principle-Based Reserves for Variable Annuities – 2022 Edition of VM-21” (Practice Note Supplement), February 2022#

  • Publisher: Variable Annuity Reserves & Capital Work Group, Life Practice Council, AAA

  • URL fetched: https://actuary.org/wp-content/uploads/2022/02/VA_PN_Supplement_Final.pdf

  • Retrieved: YES (34-page PDF; introduction, acronym list, background, C-3 Phase 2 Q&A and disclosures Q&A read)

R5. American Academy of Actuaries — “Utilization Assumptions of Guaranteed Living Benefits for Deferred Annuities: A Resource and Discussion Guide”, May 2024#

  • Publisher: Life Experience Committee, AAA (Donna Claire, chair)

  • URL fetched: https://actuary.org/sites/default/files/2024-05/life-paper-GLBs.pdf (note: www.actuary.org 301-redirects to actuary.org; the redirect target was fetched directly)

  • Retrieved: YES (18-page PDF, read in full including both sample utilization tables)

  • Carried-over caveat: the sample utilization tables are built for a non-qualified FIA, not a VA, and must be applied with care.

R6. U.S. Securities and Exchange Commission — Form N-4 (reference copy, version effective September 23, 2024)#

  • URL fetched: https://www.sec.gov/files/formn-4.pdf

  • Retrieved: YES (65-page PDF; general instructions and item index read)

  • Note: this product research file retrieved Form N-4 successfully with a declared User-Agent; the cross-product entry REG-R52 records a failed fetch of the same URL (HTTP 403). Prefer R6 for first-hand Form N-4 facts.

R7. SEC Rule 498A, 17 CFR 230.498A — summary prospectuses for variable annuity and variable life contracts#

  • URL fetched: https://www.law.cornell.edu/cfr/text/17/230.498A

  • Retrieved: YES

R8. FINRA Rule 2330 — Members’ Responsibilities Regarding Deferred Variable Annuities#

  • URL fetched: https://www.finra.org/rules-guidance/rulebooks/finra-rules/2330

  • Retrieved: YES

R9. Internal Revenue Code § 72 — Annuities; certain proceeds of endowment and life insurance contracts#

  • URL fetched: https://www.law.cornell.edu/uscode/text/26/72

  • Retrieved: YES

R10. Treas. Reg. § 1.817-5 — Diversification requirements for variable annuity, endowment, and life insurance contracts#

  • URL fetched: https://www.law.cornell.edu/cfr/text/26/1.817-5

  • Retrieved: YES

R11. Actuarial Standards Board — ASOP No. 52, “Principle-Based Reserves for Life Products under the NAIC Valuation Manual”#

  • URL fetched: http://www.actuarialstandardsboard.org/asops/principle-based-reserves-life-products-naic-valuation-manual/

  • Retrieved: YES

  • Carried-over caveat: the retrieved text scopes ASOP 52 to policies “subject to VM-20 requirements”. Treat any claim that “ASOP 52 governs VM-21” as unverified.

R12. Actuarial Standards Board — Standards of Practice index (titles and effective dates for ASOP Nos. 22, 52, 56)#

  • URL fetched: http://www.actuarialstandardsboard.org/standards-of-practice/

  • Retrieved: YES

R13. Society of Actuaries Research Institute & LIMRA — “2022–2024 Variable Annuity Guaranteed Living Benefit / Contract Holder Behavior Study”#

  • URL fetched: https://www.soa.org/resources/experience-studies/2025/2022-24-va-livingbenefit/

  • Retrieved: YES (landing page only — the detailed report is a paid data package)

Cross-product regulatory references [REG-R#]#

These are cited with the [REG-R#] prefix to avoid collision with the product research file’s own R-numbering. They resolve against a single shared numbering space running R1–R157, curated at references/regulatory-and-actuarial-references.md, with most of the R73–R149 block unused:

  • R1–R34 — research provenance _research/regulatory-actuarial.md (the original life bibliography; several entries also bind annuity models, and that file’s companion table records how each one applies).

  • R35–R72 — research provenance _research/regulatory-actuarial-annuities.md (the annuity continuation of the same space; it opens at R35 precisely because R1–R34 are frozen and must not be renumbered).

  • R151–R157 — the seven NAIC Accounting Practices and Procedures Manual appendix items read at first hand on 2026-08-06: _research/appp-ag33.md (R151), _research/appp-ag35.md (R152), _research/appp-a820-a821-a822.md (R153), _research/appp-a830.md (R154) and _research/appp-a585-a250-a255-a270.md (R155, R156, R157). R150 is the NAIC principle-based reserving topic page and is not cited here. Four of the seven are cited in this directory — R151, R153, R156 and R157 — and their entries are reproduced below from references/regulatory-and-actuarial-references.md.

Entries cited by the two documents in this directory:

Tag

Short title

Research file

Retrieval status (per that file)

REG-R15

26 U.S.C. §817 (esp. §817(h)) — variable contract diversification

regulatory-actuarial.md

fetched

REG-R16

26 U.S.C. §807 — tax reserves

regulatory-actuarial.md

fetched

REG-R26

ASOP No. 2 — Nonguaranteed Elements for Life Insurance and Annuity Products

regulatory-actuarial.md

fetched

REG-R27

ASOP No. 7 — Life or Health Cash Flow Analysis

regulatory-actuarial.md

fetched

REG-R29

ASOP No. 22 — Opinions Based on Asset Adequacy Analysis

regulatory-actuarial.md

fetched

REG-R31

ASOP No. 52 — PBR for Life Products under the Valuation Manual

regulatory-actuarial.md

fetched

REG-R32

ASOP No. 56 — Modeling

regulatory-actuarial.md

fetched

REG-R34

FASB ASU 2018-12 (LDTI) — market risk benefits

regulatory-actuarial.md

no (fasb.org 403) — substance corroborated only from secondary summaries and carried as unverified in that file

REG-R35

VM-21 — PBR for Variable Annuities (Valuation Manual, Jan. 1, 2026 ed.)

regulatory-actuarial-annuities.md

yes (local text extraction)

REG-R36

VM-22 — PBR for Non-Variable Annuities (Jan. 1, 2026 ed.)

regulatory-actuarial-annuities.md

yes (local text extraction)

REG-R37

VM-V §1 — Income Annuities, maximum valuation interest rates

regulatory-actuarial-annuities.md

yes (local text extraction)

REG-R38

Actuarial Guideline XLIII (AG 43) — CARVM for Variable Annuities (VAIWG redline)

regulatory-actuarial-annuities.md

yes (local text extraction)

REG-R42

Standard Nonforfeiture Law for Individual Deferred Annuities (Model #805)

regulatory-actuarial-annuities.md

yes (local text extraction)

REG-R43

Variable Annuity Model Regulation (Model #250)

regulatory-actuarial-annuities.md

yes (local text extraction)

REG-R44

Actuarial Guideline LIV (AG 54) — ILVA nonforfeiture

regulatory-actuarial-annuities.md

yes (local text extraction, complete)

REG-R45

Annuity Disclosure Model Regulation (Model #245)

regulatory-actuarial-annuities.md

yes (local text extraction)

REG-R46

Suitability in Annuity Transactions Model Regulation (Model #275)

regulatory-actuarial-annuities.md

yes (local text extraction)

REG-R47

C-3 RBC Instructions and Appendices (C-3 Phase II for VAs)

regulatory-actuarial-annuities.md

yes (local text extraction)

REG-R48

Oliver Wyman / VAIWG — QIS II Public Report and Executive Summary

regulatory-actuarial-annuities.md

yes (local text extraction, both)

REG-R50

SEC Release 33-10765 — Rule 498A adopting release

regulatory-actuarial-annuities.md

yes (via govinfo); sec.gov PDF 403

REG-R51

17 C.F.R. §230.498A (current text, extended to registered non-variable annuities)

regulatory-actuarial-annuities.md

fetched

REG-R52

SEC Form N-4

regulatory-actuarial-annuities.md

no (sec.gov 403) — but fetched first-hand as R6 above

REG-R54

FINRA Rule 2330

regulatory-actuarial-annuities.md

fetched (same rule as R8 above)

REG-R55

26 U.S.C. §72 — Annuities

regulatory-actuarial-annuities.md

fetched (same statute as R9 above)

REG-R56

26 U.S.C. §1035 — Certain exchanges of insurance policies

regulatory-actuarial-annuities.md

fetched

REG-R57

26 C.F.R. §1.401(a)(9)-6 — RMDs for annuity contracts (QLAC rules)

regulatory-actuarial-annuities.md

fetched

REG-R58

T.D. 10001 — RMD final regulations (July 19, 2024)

regulatory-actuarial-annuities.md

yes (via govinfo)

REG-R59

Model #821 + VM-M — 2012 IAM / 2012 IAR / Scale G2 annuity mortality

regulatory-actuarial-annuities.md

yes (local text extraction, both)

REG-R61

2020–2024 Individual Payout Annuity Mortality Experience Study

regulatory-actuarial-annuities.md

yes (landing page)

REG-R62

FIA Policyholder Behavior Experience Studies (2021–22, 2019–20)

regulatory-actuarial-annuities.md

yes (both landing pages)

REG-R64

VA Contract Holder Behavior / GLB Utilization Studies (2022–24 and predecessors)

regulatory-actuarial-annuities.md

yes (2022–24 landing page; same landing page as R13 above)

REG-R66

AAA — VM-21 Practice Note Supplement (Feb. 2022)

regulatory-actuarial-annuities.md

yes (local text extraction; same document as R4 above)

REG-R67

AAA — Utilization Assumptions of Guaranteed Living Benefits (May 2024)

regulatory-actuarial-annuities.md

yes (local text extraction; same document as R5 above)

REG-R70

ASOP No. 54 — Pricing of Life Insurance and Annuity Products

regulatory-actuarial-annuities.md

fetched

REG-R71

ASOP No. 10 — U.S. GAAP for Long-Duration Life, Annuity, and Health Products

regulatory-actuarial-annuities.md

yes (local text extraction)

REG-R72

IRS LB&I §807 directive (AG 43/VM-21 tax reserves)

regulatory-actuarial-annuities.md

no (irs.gov 404) — substance unverified

Note on overlaps: R1/REG-R35, R4/REG-R66, R5/REG-R67, R8/REG-R54, R9/REG-R55, R11/REG-R31 and R13/REG-R64 are the same documents reached through two numbering spaces. Where a fact was extracted first-hand in the product research file, the [R#] tag is used; where the fact comes from the cross-product annotation, the [REG-R#] tag is used. Both are given where both apply.

AP&P Manual appendix entries (R151–R157) newly cited here#

Added on 2026-08-06, when AG 33 and the Appendix A items were read at first hand and the findings written into technical-notes.md (Known modeling pitfalls, Valuation and reserve pointers) and product-spec.md (Regulatory context). Ids, titles, publishers, URLs, access dates, fetched markers and every carried-forward limit are reproduced from references/regulatory-and-actuarial-references.md; nothing is renumbered and no flag is upgraded. Only the four items this directory actually cites are reproduced — R152 (AG 35), R154 (A-830) and R155 (A-585) are not cited here and are not carried over. Cross-references inside these entries to ids not reproduced here — R73 (the AP&P Manual As of March 2026), R33, R39, R110, R101/R102, R1 and R6 — resolve in references/regulatory-and-actuarial-references.md.

One physical document behind R151–R157. All seven are appendix items of the NAIC Accounting Practices and Procedures Manual, As of March 2026 — the same 2,117-page consolidated PDF already catalogued as R73, a free download from content.naic.org (catalogue entry “APPM-2026 … Free Download” on https://content.naic.org/publications; file https://content.naic.org/sites/default/files/publication-app-manual.pdf). They take appendix-level ids rather than being folded into R73 so a document can cite A-820 ¶15 or AG 33 Text 4 instead of a 2,117-page manual. Each was read by local text extraction from that download. This supersedes, for these items, the library’s earlier record of the manual as a paid publication that could not be fetched REG-R33 — frozen and preserved unaltered in references/regulatory-and-actuarial-references.md.

Edition line, stated once for all seven. None of these items prints “As of March 2026” on its own pages. Every extracted page carries only the footer “© 1999-2026 National Association of Insurance Commissioners”, which is a copyright span, not an adoption, effective or revision date for any of these instruments and must never be cited as one. The “As of March 2026” designation is the manual’s own front matter, recorded at R73. The AP&P Manual licence applies unchanged to all of R151–R157: personal and non-commercial use, no integration “into any software or other publication” without written NAIC permission, so these items are paraphrased with a paragraph cite and quoted only in short anchors.

A-270 (Variable Life Insurance) was extracted alongside R155 at printed pages A270-1 to A270-3 = PDF pages 1097–1099, but the extraction assigned it no reference id. Nothing in this directory is cited from it, and its guaranteed-minimum-death-benefit reserve construction is therefore outside the library.

REG-R151. Actuarial Guideline XXXIII — Determining CARVM Reserves for Annuity Contracts With Elective Benefits (AG 33), as printed in the AP&P Manual#

  • Publisher: NAIC

  • URL: https://content.naic.org/sites/default/files/publication-app-manual.pdf — Appendix C — Actuarial Guidelines; printed pages AG33-1 to AG33-8 = PDF pages 1496–1503; same physical document as R73

  • Accessed: 2026-08-06

  • Fetched: yes (local text extraction; all eight printed pages read in full — Background Information, Purpose, Definitions, Text 1–7 and Effective Date)

  • Limits carried forward from _research/appp-ag33.md: the running heads confirm Appendix C, but these pages carry no volume statement — the Volume II placement is R73’s record, not theirs. They carry no amendment history, no adoption note and no revision log, so the guideline’s printed Effective Date of 31 December 1998 cannot be reconciled here against the 31 December 1995 date the library carries from IRS Rev. Rul. 2002-6 for a differently-titled instrument; both are recorded and neither is presented as settled. AG 33 contains no formulas, symbols, tables or factors beyond the 7% expense allowance and the 1998–2000 phase-in percentages, and names no other guideline anywhere — not AG 35, not AG 43. Cite by block (Background / Definitions / Text), since all three restart at 1. Spurious intra-word spaces at justified-line breaks are text-layer artefacts and were closed up in the research file’s quotations.

  • Supersedes in fact: R39 (“guideline text not retrieved”), which is frozen and is preserved unaltered in references/regulatory-and-actuarial-references.md.

  • Note for this directory: cited for scope, the precedence clause, the elective/non-elective classification and the prohibition on experience-based elective incidence — not for any parameter of this model. AG 33 never mentions separate accounts, variable annuities, the Valuation Manual or PBR, so its displacement by AG 43/VM-21 rests on its general precedence clause and is marked [std, derived] where it is relied on.

REG-R153. Appendix A-820 — Minimum Life and Annuity Reserve Standards (with Appendix A-821, Annuity Mortality Table for Use in Determining Reserve Liabilities for Annuities, and Appendix A-822, Asset Adequacy Analysis Requirements)#

  • Publisher: NAIC

  • URL: https://content.naic.org/sites/default/files/publication-app-manual.pdf — Volume I, Appendix A — Excerpts of NAIC Model Laws; A-820 printed A820-1 to A820-13 = PDF pages 1186–1198, A-821 printed A821-1 to A821-6 = PDF pages 1199–1204, A-822 printed A822-1 = PDF page 1205; same physical document as R73

  • Accessed: 2026-08-06

  • Fetched: yes (local text extraction; A-820 ¶¶1–28 read in full, A-821 read in full including the 2012 IAM Period Table and Projection Scale G2 printed at its Appendices I–IV, and A-822’s four paragraphs read in full)

  • Limits carried forward from _research/appp-a820-a821-a822.md: “As of March 2026” is not printed on PDF pp. 1186–1205 — cite the copyright footer for what those pages print. A-821 prints only the 2012 IAM Period Table and Projection Scale G2; the 1994 GAR table and its AA_x factors, the Annuity 2000 table and 1983 Table “a” are named and not printed, so A-821 ¶16 is not computable from library sources, and no standard is printed for individual annuities issued before 1 January 2001. A-820 names its life mortality tables without printing them and the 2017 CSO is nowhere in its text. Three text-layer repairs are recorded in the research file rather than hidden: the lost fraction bar at ¶7.a.i(a) (the term is (W/2)·(R2 − .09)), the lost R1/R2 subscripts, and the ¶8.c weighting-factor tables, which were reassembled by column position from a scrambled layer. Two internal oddities are recorded as printed and not reconciled: ¶22’s empty window and ¶7’s “effective date of the Codification”, a threshold whose date A-820 never prints. Naming trap: AP&P Appendix A-822 is not NAIC Model #822 (R101/R102) — A-820’s own header does not list Model #820 while A-822’s does.

  • Supersedes in fact: the A-820 half of R110’s limit (“A-820 and A-830 as printed in the AP&P Manual were not retrieved”), and, for the paragraphs it carries, the reliance on R1 and R6 alone. R110 is frozen and is preserved unaltered.

  • Note for this directory: cited only as the destination of A-250 ¶3’s delegation and for the fact that its ¶15 is the CARVM construction. No A-820 mechanic, rate, weighting factor or mortality table is stated anywhere in this directory — this product’s reserve is VM-21’s.

REG-R156. Appendix A-250 — Variable Annuities#

  • Publisher: NAIC

  • URL: https://content.naic.org/sites/default/files/publication-app-manual.pdf — Volume I, Appendix A — Excerpts of NAIC Model Laws; printed page A250-1 = PDF page 1095; same physical document as R73

  • Accessed: 2026-08-06

  • Fetched: yes (local text extraction; the whole item read in full — three paragraphs, seven printed lines of substance)

  • Limit, and it is the point of the entry: A-250 is a pointer, not a reserve method. It gives a definition, a separate-account asset-coverage requirement, and a delegation of the reserve itself to Appendix A-820 “in accordance with actuarial procedures that recognize the variable nature of the benefits provided and any mortality guarantees”. It contains no formula, no symbol, no factor, no table, no CARVM adaptation, no elective-benefit path rule, no interim-value rule and not the word CARVM, and prints no effective date. It is cited in this directory for that verified negative finding as much as for anything it supplies.

  • Note for this directory: its header names only the Standard Valuation Law (#820) and SSAP No. 56—Separate Accounts — it does not name Model #250, so every Model #250 statement in product-spec.md continues to rest on REG-R43 and not on this print. All three of its paragraphs sit under the heading “Definitions”; there is no “Valuation Requirements” heading in the item, which is recorded as printed and does not change the effect of ¶3.

REG-R157. Appendix A-255 — Modified Guaranteed Annuities#

  • Publisher: NAIC

  • URL: https://content.naic.org/sites/default/files/publication-app-manual.pdf — Volume I, Appendix A — Excerpts of NAIC Model Laws; printed page A255-1 = PDF page 1096; same physical document as R73

  • Accessed: 2026-08-06

  • Fetched: yes (local text extraction; the whole item read in full — seven paragraphs)

  • Limit: like A-250, A-255 delegates the reserve method itself to Appendix A-820; what it adds is three operative rules — the separate account liability must be at least the surrender value produced by the contract’s own market-value-adjustment formula, a shortfall against the market value of the separate account assets must be made good by a transfer into that account, and any additional reserve needed to cover future guaranteed benefits must be established. No MVA formula and no parameters for one are printed — the formula is the contract’s. Like A-250 it contains no formula, symbol, factor or table, does not mention CARVM, and prints no effective date. Its ¶1 definition is separately load-bearing as the test VM-21 §2.A.2 uses to exclude contracts falling under VM-A item A-255 (R35); that exclusion is VM-21’s text, not A-255’s.

  • Note for this directory: the representative contract has no fixed account and no MVA — the Roll-up GMDB election removes the Fixed Account Options S1 — so A-255 is cited only in the MVA-variant pitfall in technical-notes.md, and cited there for what it does not print.

Provenance note#

Extraction details live in _research/variable-annuity.md: that file records which fact came from which source, its unverified flags, and its “Gaps and caveats” section — in particular that no closed-form MVA factor was found in any of the four prospectuses read; that guaranteed annuity purchase rate tables were not obtained; that the SOA/LIMRA behavior study detail is paywalled, leaving the VM-21 §6.C prescribed tables R1 and the AAA sample tables R5 as the only public numeric behavior anchors; that rate sheets are volatile by design; that fund expense ranges carry lagging as-of dates; and that GMAB mechanics, RILA buffer/floor structures and New York Regulation 213 are outside its scope.

_research/regulatory-actuarial-annuities.md plays the same role for the R35–R72 half of the [REG-R#] space, including its own verified corrections carried into these documents: Model #245 (not #250) is the Annuity Disclosure Model Regulation; the Model #805 indexed nonforfeiture rate floor is 15 basis points, not 1%; VM-22 in the 2026 edition is entirely the PBR framework with income-annuity valuation rates in VM-V §1; AG 43 is not simply superseded by VM-21; and there is no ASOP for principle-based reserves for annuities. _research/regulatory-actuarial.md plays that role for R1–R34.

_research/appp-ag33.md (R151) and _research/appp-a585-a250-a255-a270.md (R155–R157, plus the unnumbered A-270) are the ground truth for the AP&P Manual appendix material added on 2026-08-06, and _research/appp-a820-a821-a822.md for R153. Their two findings that bear on this product are both negatives, and are cited as such: A-250 supplies no reserve method for a variable annuity, only a definition, a per-account asset-coverage floor and a delegation to A-820; and A-255 prints no market-value-adjustment formula, the formula being the contract’s. Neither the ¶16 guaranteed-minimum-death-benefit reserve construction of A-270 nor anything else in that item is used anywhere in this directory, A-270 having no reference id.

Standardizations marked std in product-spec.md and technical-notes.md are introduced at drafting and are not attributable to any source.

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